Other

ID sylw: 107847

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

The Government has a National Design Guide and National Model Design Code which are in place to guide design of development. Introduction of different design codes covering a range of geographic areas and with varying degrees of detail, is supported by national planning policy, including NPPF Paragraph 134, which states design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale. There would be no need to replicate the content of the National Design Guide and National Model Design Code in the SWLP Part 1.; it will be sufficient to simply refer to the document(s).

Whilst our client supports high-quality design and design codes in principle, it is important that innovation and the need to respond to the unique requirements of a site are not unduly inhibited by an overly prescriptive approach. The individual character of each site and settlement should be considered on a case-by-case basis in terms of design. There must be flexibility within the Design Codes and Local Plan policy to allow developments to come forward even if not strictly in accordance with all criteria. It should not be used as a blanket reason to refuse development where divergences do not have detrimental impacts.

Yes

ID sylw: 107848

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

The draft policy direction is considered to provide a suitable framework for a strategic historic environment policy, which would be justified and consistent with the NPPF.

Yes

ID sylw: 107849

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

There is no objection to this policy direction, which is consistent with the NPPF. Paragraph 187(e) states that new and existing development should be prevented from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution, whilst Paragraph 199 notes that planning policies should sustain and contribute towards compliance with relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas.

Other

ID sylw: 107850

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

There is clear support within the NPPF (Section 8) for the creation of healthy and safe communities, and Paragraph 005 of the Healthy and Safe Communities section of the PPG highlights that health impact assessments can be a useful tool where there are expected to be significant impacts on health. The policy direction states that where there will be a significant impact on health and wellbeing, and this cannot be mitigated, applicants will need to compensate for such impacts, through financial contributions.

Viability should be taken into consideration; it is imperative for such a policy to not risk undermining the deliverability of much-needed housing sites, in instances where it may be challenging to provide adequate mitigation. This should have been acknowledged within the SA, in relation to potential impacts on SA Objective 9 (Housing).

Other

ID sylw: 107851

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

The policy direction broadly conforms with national policy requirements. Catesby Estates Plc are supportive of the aspiration to encourage sustainable transport and reduce reliance on private vehicles. The policy needs to acknowledge that given the spatial spread and rural nature of much of South Warwickshire, use of the private car will still be the preferred (and, in some cases, only) option for many residents, in the short-to-medium term.

The Council should therefore ensure there are appropriate parking standards in place for new developments. Concurrently, the Council should seek to identify and support improvements to sustainable transport throughout the plan period, to reduce dependency on private vehicles to a greater degree in the decades ahead. Residents should have the opportunity to use efficient and reliable public transport and safely walk or cycle to destinations where possible, as acknowledged in the policy direction.

It is stated that proposals must demonstrate how they will incorporate or contribute to high-quality infrastructure that facilitate sustainable travel. Commentary with regards to infrastructure provision has already been provided in relation to Policy Direction 5, and similar considerations apply here. It is recommended that the policy provides some flexibility, clarifying which types of proposals should address this within submissions (i.e. major development, but not renewable schemes, where this is not applicable).

No

ID sylw: 107852

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

Electric vehicle charging is already addressed within Warwick’s Parking Standards SPD and Stratford’s Part R – Air Quality SPD. Moreover, Policy Direction 31 already refers to charging infrastructure for electric vehicles. It is unclear as to why the Councils consider that a standalone Part 1 policy is required which duplicates existing adopted planning guidance and the preceding policy direction, and thus it is considered that this policy direction is repetitive and can be deleted. The Councils could consider referring to this in a more detailed Part 2 policy.

Other

ID sylw: 107853

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

The content in this policy direction is supported. It is consistent with the NPPF, including Paragraphs 119 and 120, which highlight the importance of advanced, high quality and reliable communications infrastructure. This is essential for economic growth, social wellbeing, and supporting rural villages, in line with Paragraphs 82 and 83 of the NPPF.

However, the name of the policy direction, ‘Smart Cities’, is perhaps inappropriate for South Warwickshire, which consists of large rural areas, many smaller settlements, and no cities. The Government’s Post Note on Smart Cities (no. 656, September 2021) defines ‘smart city’ projects as “digital technologies and data to improve places by providing citizens with social, economic, and environmental benefits”. As the name suggests, smart city technologies are mostly deployed in urban areas and would not be applicable to most of Stratford and Warwick districts. The policy direction itself makes no reference to the term ‘smart cities’, with no definition provided (leaving this open to interpretation), nor are technologies included which could be described as ‘smart’. Most of the focus is on high-speed broadband. The policy should be renamed to better reflect its content and local geography or revised with a greater emphasis on smart city technologies and applications, with a clear relevance to South Warwickshire, including its rural settlements; for example, by clarifying whether such technologies should be incorporated into developments of a certain nature and scale, across the district, or restricted to schemes within or on the edge of urban areas.

Other

ID sylw: 107854

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

This policy direction is broadly supported, with Paragraphs 187 and 192 of the NPPF setting out the requirements to protect and enhance biodiversity. However, the policy direction suggests that the final policy will follow the principles outlined in the Lawton Report (Making Space for Nature: A review of England’s Wildlife Sites and Ecological Network). This was published in September 2010. Paragraph 32 of the NPPF is clear that plans should be underpinned by the latest available evidence. Whilst this report is not strictly part of the evidence base, it is nonetheless clearly being used to shape the content and structure of the policy. By the time the SWLP Part 1 is adopted, it will be almost two decades since the publication of the Lawton Report. More recent reports and studies should be consulted to ensure that the policy reflects the latest thinking and most effective approaches to the protection and conservation of species.

No

ID sylw: 107855

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

This policy will require proposals to support the principles of Local Nature Recovery Strategies (LNRS). LNRS are a statutory requirement under the Environment Act 2021, and Councils are not obliged to duplicate this in a development plan policy. The justification for the policy provided by the Council is inadequate, and it is considered that the policy is unnecessary.

Other

ID sylw: 107856

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

The Environment Act 2021 stipulates developments must provide a Biodiversity Net Gain of at least 10%. Our client affirms there is no need for a policy in SWLP Part 1 which duplicates this statutory requirement. It would be sufficient and consistent with the NPPF to state that a net gain will be sought in accordance with latest statutory requirements. These may change over the plan period.

If the Councils seek to specify a requirement greater than 10% this will need to be fully supported by the latest evidence to ensure the policy is justified. This evidence is currently unavailable. This approach could result in negative effects with regards to SA Objectives 9 (Housing) and 13 (Economy) due to impacts on costs and viability. This should have been recognised in the SA. It potentially requires more land to deliver the BNG, meaning sites need to be larger. It is considered the Council should not establish standards which go beyond the statutory requirements.

Any biodiversity policy should be drafted to provide as much flexibility as possible. The policy direction recognises this, which is supported. The test is whether 10% is delivered, not the method. As set out in the Environment Act, gains can be provided through enhancing biodiversity on site, a combination of on and off-site delivery (with the latter on land owned by the developer outside of the red line boundary, or through the purchase of off-site biodiversity units), or, alternatively, biodiversity credits can be purchased. The way in which ‘net gains’ are calculated must be carefully considered and a pragmatic view should be taken in terms of the delivery.